Small Business Subcontracting Plan

Typical Content

• Total subcontracting dollars and small business percentage goals
• Goals by category: SDB, WOSB, HUBZone, SDVOSB, VOSB
• Description of principal products and services to be subcontracted
• Method of developing subcontracting goals
• Indirect cost treatment for subcontracting goals
• Program administrator identification and responsibilities
• Outreach efforts and mentoring programs
• Reporting and compliance monitoring procedures

Common Mistakes

• Setting unrealistically high goals that cannot be achieved
• Not identifying specific subcontracting opportunities for small businesses
• Failing to name the program administrator responsible for plan execution
• Copying goals from a previous contract without tailoring to current requirements
• Not including a good faith effort clause or corrective action process
• Submitting a plan that does not meet the minimum statutory requirements of FAR 19.704

Best Practices

• Set achievable goals based on market research of small business capabilities
• Identify specific work packages that are suitable for small business performance
• Name an experienced Small Business Program Administrator with adequate authority
• Include mentor-protege relationships and joint venture opportunities
• Track subcontracting performance monthly and report in eSRS (ISR/SSR)
• Engage the agency OSBP early for guidance on acceptable goal levels

Evaluation Weight

Typically evaluated on a pass/fail or acceptable/unacceptable basis as a separate evaluation factor. While not usually scored against technical or price, an unacceptable subcontracting plan can render the proposal ineligible for award. Some agencies give credit for exceeding minimum small business goals as part of the technical evaluation.

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